COMMUNITY HOUSING IMPROVEMENT PROGRAM
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
The Community Housing Improvement Program (CHIP) opposes the
above-referenced changes to Community Reinvestment Act (CRA)
regulations. The Community Reinvestment Act, as currently written, is
crucial to the community development work that CHIP performs in rural
Northern California.
Under the current CRA regulations, many banks in our service area of
Butte, Glenn, Tehama, Shasta and Lassen Counties, those with assets of
at least $250 million, are rated by performance evaluations that
provides them with an incentive to provide lending, investing, and other
services to low- and moderate-income households. The proposed changes
will eliminate the incentive for state-charted banks with assets between
$250 million and $1 billion. In place of the investment and service
parts of the CRA exam, the FDIC proposes to add a community development
criterion, which will reduce the banks' responsibilities to cover all
service areas.
In rural California, nearly 90% of the financial institutions will no
longer be required to be accountable under the current CRA regulations.
This will make it difficult for groups like CHIP to provide affordable
housing and community development services, particularly at a time when
housing affordability in rural California is at historical low levels.
Without a source of commercial capital, fewer housing units will be
constructed.
I urge you to withdraw your proposed regulation changes.
David Ferrier
Executive Director
Community Housing Improvement Program
1001 Willow Street Chico, CA 95928
Cc: Senators Feinstein and Boxer
Congressman Herger
